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Yes, you can get an Importer Exporter Code (IEC) without having a GST registration, but it depends on the nature of your business. As per the current guidelines of the Directorate General of Foreign Trade (DGFT), GST is not mandatory for obtaining an IEC if you are not liable to be registered under GST laws. This means that individuals or entities not engaged in taxable supplies under GST—such as those only dealing in exempt goods or services, or small businesses below the GST threshold—can still apply for IEC.
However, if you do have a GSTIN, it is advisable to declare it while applying for the IEC. In fact, when a GSTIN is provided, the PAN-based IEC gets automatically linked with the GST database. But in cases where the applicant is not registered under GST, the IEC is issued solely based on the PAN of the individual or entity. PAN is the only mandatory requirement for IEC, whereas GSTIN is optional unless your business requires GST compliance.
Keep in mind that even if GST is not required for IEC registration, it may become relevant later when you start importing or exporting goods that fall under the GST net. In such cases, GST compliance will be necessary for claiming input tax credits or refund of IGST paid on exports.
So, in summary, you can obtain an IEC without GST registration as long as your business does not require GST under Indian tax laws. But for most commercial operations, especially involving goods, having GST may be essential at later stages.